Dear Board of Medicine,

Having more votes in favor does not mean it's more correct or safer. As you know, ATs outnumber, Licensed Acupuncturists 3:1 in Virginia. They will naturally have more comments in favor.

What I ask you to consider: Does the Board want to assume more risk to itself, the supervising physicians of the AT, and the public by allowing people with very little training (currently, Virginia Law and regulations does not have a definition of Dry Needling, has no minimum education requirements defined, and most schools only teach one class, approximately 45hrs) versus Virginia's needle specialists, with a legal definition and established regulations of training with a minimum of 1,650 hours of acupuncture needles training.

Does Board of Medicine want to take on more risk with no legal definition, education requirements, or safety standards? 

Let's be clear: Dry Needling (DN) is a type of Acupuncture but not all Acupuncture is dry needling. 

If indeed DN is different from Acupuncture, as ATs claim, then a legal definition is required and solid evidence is needed. Former legislative processes asked PTs to define DN two years ago and yet the PTs, DCs and ATs have not defined it.  My speculation is because it is NOT legally different from already defined "Practice of Acupuncture" https://law.lis.virginia.gov/vacode/title54.1/chapter29/section54.1-2900/ "Practice of acupuncture" means the stimulation of certain points on or near the surface of the body by the insertion of needles to prevent or modify the perception of pain or to normalize physiological functions, including pain control, for the treatment of certain ailments or conditions of the body and includes the techniques of electroacupuncture, cupping, and moxibustion. The practice of acupuncture does not include the use of physical therapy, chiropractic, or osteopathic manipulative techniques; the use or prescribing of any drugs, medications, serums or vaccines; or the procedure of the five needle auricular acupuncture protocol (5NP) as exempted in § 54.1-2901."  The national definition of DN by the FSBPT is almost verbatim to the above definition of "Practice of Acupuncture."

Yes, Athletic Trainers, like PTs, are taught dry needling in school (one class, approximately 45 hours).  Ask any AT or PT who is also a Licensed Acupuncturist and you will learn, dry needling is a type of orthopedic Acupuncture.  In fact, I learned Dry Needling in my Orthopedic Acupuncture class back in 2009. While Acupuncture has its roots in Chinese Medicine Classical theory, the modern version of Acupuncture taught in Masters and Doctoral level colleges and universities includes nearly 45% of allopathic, western medicine. Acupuncture has been taught in a bio-medical and traditional way in the U.S. since state and national credentialing was granted and more bio-medical models continue to be integrated in all Acupuncture programs around the globe. Where do you think Dry Needling came from? Orthopedic Acupuncture. From Acupuncturists. 

Apparently ATs think their training is sufficient, but I will ask you if you had to take your own family member to receive the insertion of acupuncture needles (yes, to perform Dry Needling, they buy FDA approved Acupuncture needles), would you prefer the person who took a one semester class or continuing education equivalent (approximately 45 hours) or someone who spent 1,650 minimum hours (Virginia's current legal requirements per the above code)? Is the Board willing to take on that risk and liability?  Do ATs really want to take on that risk and liability?

ATs currently require the supervision of a physician for practice. This adds another level of risk, especially if their supervising physician is not trained in Medical Acupuncture or Dry Needling. Who is going to supervise this invasive procedure?  Are all supervising physicians going to be required to have their 200hours if acupuncture needles training, already established in Virginia Law?